Relevant tax modifications 2024/2025
On 21 November last, the Congress of Deputies approved the Bill establishing a Complementary Tax to guarantee a global minimum level of taxation for multinational groups and large national groups. This Bill will continue its parliamentary procedure in the Senate, returning to Congress for final approval probably at the end of December.
This is an important legal provision, a consequence of the implementation in Spain of what is known as Pillar II of Action 1 of the BEPS Project, led by the OECD, which started remotely in 2008 and has been gradually developing since then. However, this legislative initiative has been more widely publicised in the media, not because of the tax itself, but because the government has taken advantage of its parliamentary processing to incorporate, by means of numerous amendments to the legal text, relevant modifications to other tax regulations, thus affecting taxes such as corporate income tax, personal income tax and excise duties, among others, and even incorporating the creation of new taxes. The parliamentary process has been intense, with meetings of the Finance Committee ending in the early hours of the morning and heated debates between the different parliamentary groups.
We will deal with these modifications in this Alert, leaving the complex Complementary Tax for a much more detailed analysis once its legal regulation has been definitively approved. It is now appropriate to rank those "additional" elements offered by the legislative initiative, as some of them are immediately, and even retroactively, applicable. To do so, we will use a classic scheme, tax by tax, ranking those provisions that will come into force in 2024. We will also include at the end a brief reference to the provisions that have not been approved by Congress.
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